This Privacy Policy describes how Coupl Technologies, Inc. (“Senda,” “we,” “us,” or “our”), a Delaware corporation, collects, uses, shares, and protects personal information when you use the Senda mobile application, website, and related services (the “Services”).
1. Who We Are
Senda partners with Saber Money Canada Inc. (“Partner”) to provide the underlying money transmission services. The Partner processes certain personal information as an independent controller/processor under its own privacy policy, available at [PARTNER PRIVACY POLICY URL], in addition to this Policy.
2. Information We Collect
We collect the following categories of information:
- Identity information: full name, date of birth, government ID number/document, Social Security Number or equivalent, photograph (for KYC verification), and similar identifiers, from you and/or your beneficiary.
- Contact information: email address, phone number, mailing address.
- Financial information: linked bank account or debit card details, transaction history, transfer amounts, beneficiary bank account details (including Indian bank account number and IFSC code).
- Device and usage information: IP address, device identifiers, app usage data, log data, and approximate location (where permitted by your device settings).
- Communications: records of your communications with our customer support, and SMS/email opt-in status and message history.
3. How We Use Your Information
- To create and maintain your account, and verify your identity (KYC/AML compliance);
- To process and complete your money transfers, including sharing necessary information with the Partner and its banking/payment partners in the US and India;
- To detect, investigate, and prevent fraud, money laundering, and other illegal activity, and to comply with our legal and regulatory obligations under US and Indian law;
- To send you transactional communications about your transfers via SMS, email, or push notification, where you have opted in (or where required regardless of opt-in status, e.g., critical account/security alerts);
- To provide customer support and respond to your inquiries;
- To improve and maintain the Services, including analytics on app performance and usage.
We do not use your financial or identity information for targeted advertising, and we do not sell your personal information, as “sale” is defined under the CCPA/CPRA. [CONFIRM: if this is not accurate, this section must be revised before publication.]
4. How We Share Your Information
We share personal information with:
- Saber Money Canada Inc. (our money transmission partner) and its sub-processors/banking partners, to execute your transfers;
- Banks, payment networks, and financial institutions in the US and India necessary to complete a transfer, including the receiving bank of your beneficiary;
- Identity verification and fraud-prevention service providers;
- SMS and email service providers, solely to deliver the communications described in Section 3;
- Regulators, law enforcement, or government authorities in the US or India, where required by law, subpoena, or regulatory request (e.g., FinCEN, OFAC, RBI, or equivalent);
- Professional advisors (legal, audit) and successors in the event of a merger, acquisition, or sale of assets.
We do not share your information with third parties for their own independent marketing purposes.
5. Cross-Border Data Transfers
Because Senda facilitates transfers between the United States and India, your information (and your beneficiary’s information) will necessarily be transferred to, and processed in, India and potentially other jurisdictions where our service providers operate. By using the Services, you consent to this cross-border transfer. [PLACEHOLDER — mechanism for transfer (e.g., contractual safeguards) to be confirmed with counsel in light of India’s DPDP Act requirements once notified/in force.]
6. Data Retention
We retain identity verification and transaction records for the period required under applicable Bank Secrecy Act / AML recordkeeping rules (typically a minimum of five years after the relevant transaction), and other personal information for as long as necessary to provide the Services or as required by law, after which it is securely deleted or anonymized.
7. Your Rights and Choices
- You may access, correct, or request deletion of certain personal information by contacting us at [SUPPORT EMAIL], subject to our regulatory recordkeeping obligations, which may limit deletion of transaction-related records.
- You may opt out of SMS communications at any time by replying STOP, and of marketing emails via the unsubscribe link, without affecting your ability to receive required transactional or legal notices.
- If you are a California resident, you may have additional rights under the CCPA/CPRA, including the right to know, delete, and correct your personal information, and to non-discrimination for exercising these rights. [PLACEHOLDER — full CCPA notice to be finalized with counsel.]
8. Data Security
We use administrative, technical, and physical safeguards designed to protect your personal information, including encryption of sensitive data in transit and at rest, and access controls limiting employee access to personal information on a need-to-know basis. No system is completely secure, and we cannot guarantee absolute security.
9. Children’s Privacy
The Services are not directed to, and we do not knowingly collect personal information from, individuals under the age of 18. If we learn we have collected such information, we will delete it promptly.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified to you via the app, email, or SMS prior to taking effect.
11. Contact Us
Coupl Technologies, Inc.
355 Bryant ST, Unit 403,
San Francisco, California 94107, United States of America